It is wonderful to see more regulation being brought forth regarding the use of Assistants.  I highly support adopting any of ASHA's recommendations for using SLPAs, which have clearly been reviewed in creating these new policies.  I would still like to see a licensure for SLPAs. Thank you.

An assistant should not have any capability to design therapy or to modify therapy. They should not have capacity to sign any forms, attend IEP meetings without the SLP in attendance, communicate with parents without the knowledge of the SLP. One must be care to recognize that many SLPs have a strong Masters Degree, with supervised clinical fellowship of 1 to 2 years, depending on the student and have been highly trained. the assistants have not received nearly as much training and have not been trined to direc therapy on their own. I am strongly opposing any form of autonomy given to SLPAs.

 

On the plus side, this proposal includes a good restriction in that an SLP may only supervise two Assistants at a time - this is crucial so that employers do not water down professional services by spreading fully licensed SLPs over many assistants. However, Virginia should require Assistants to be licensed. This proposal leaves too much unsaid about the qualifications required.  It states that the Assistant must have an Associate's or Bachelor's Degree without specifying the discipline in which the degree is earned. Virginia qualifications should follow other states with successful SLP Assistant Programs already in place (e.g. North Carolina) and specifically state the degree requirements.  For example, in North Carolina the Assistant must be licensed by the same state Board that licenses full SLPs, and the degree requirement is an Associate's Degree from a Speech Language Pathology Assistant program, or a Bachelor's degree with specific course requirements in speech pathology. Maybe Virginia should do require the same.

Virginia should regulate SLPAs as per ASHA. We don't need to be inventing some 'Virginia Way'. Regulatory Action should also clarify what term we're using- ASLPs (Assistant SLP) or SLPA (SLP Assistant) - and line up with the ASHA term.

Does this Regulatory Action cover those individuals in the public schools who get hired off a substitute list for 10 extra hours of training by the SLP Coordinator if they are given a title other than SLPA or ASLP, such as Speech Therapist Assistant, Speech Therapist Substitute? At this time, new staff are introduced at SLP meetings and we don't know if they're SLPs or not. Same goes when these 'assistants' are assigned a caseload. Who has the responsibility to tell admin and staff who is in the building- a SLP or a SLPA? Is there any responsibility to inform the parents who's the service provider? Why so covert about this?

In past years, 'assistants, aides, subs' have signed off on IEPs, conducted evals because they were not given written documentation of the limits of their duties.  SLPs assumed they were being supervised by someone else when they may not have had any supervision at all because the SLP Coordinator resigned. No one seems to question what is going on. The OTRs have their act together and make sure to clarify to school personnel when they're in public school buildings who are the OTRs and who are the COTAs and their limitations as well as what 'supervision' looks like, rather than what SLP may be doing, such as a bi-annual email? 'how's it going?" and not telling staff if the person is a SLP, SLPA, aide. SLP supervisors, coordinators should be doing the same as OTRs. Be upfront with the info.

I suspect there is an economic impact, especially on the public schools. Salaried public school staff, with apparently lower salaries than private practice but with steady, predictable hours (and summer flexibility to practice privately or not)  with retirement and health insurance, seem to be on the way out. Contracted personnel are increasing. It also seems there's high turnover so there's no real connection to a school (schools don't want to pay for contractors to be at faculty meetings, department meetings, back to school nights). So in 10 years will the cheaper SLPAs be the main service providers in the public schools with a SLP supervising dozens of them?  Is this a move forward or backward in the practice? As noted in the Regulatory action, supervision by a SLP should be to a limited and specified number of SLPAs.

TFirst and foremost SLPAs should absolutely have minimal educational requirements of a bachelor’s degree specific to communicative sciences and disorders.  It is troubling that it’s even suggested that a person in an unrelated field can provide appropriate and effective services with no formal knowledge of the principles related to speech language pathology.  On the job training is an insufficient method of providing an adequate level of training to an assistant to provide treatment to vulnerable consumers who won’t realize that they are potentially receiving subpar services from a person who possibly has a degree in an unrelated field with no background knowledge of communication disorders.  Certified SLPs are highly trained clinicians who must meet state and national standards.  We should not look to denigrate the profession with unqualified, unprepared individuals. The proposed guidelines are too broad and nonspecific and leave too much responsibility on the SLP to train the SLPA, who would have no accountability for their actions. Qualified SLPAs who meet educational requirements specific to the field of speech language pathology should be licensed and required to maintain annual minimal standards that are regulated by the board.  I personally do not support any less. ype over this text and enter your comments here. You are limited to approximately 3000 words.

I agree with other comments that SLP-As should hold a bachelor’s degree specific to communicative sciences and disorders.  I also agree with other comments that qualified SLP-As who have met the educational requirements specific to the field of speech language pathology should be licensed and required to maintain annual minimal standards that are regulated by the board.  I do not support any lesser requirements.

With thorough ASHA oversight in development and implementation, and an associate's or bachelors in speech or communication disorders for the SLPA's, I see many benefits to this proposal -- as long as the supervising SLP retains primary interaction (perhaps 60-75%) with clients.  It is a need long recognized with caseloads of 65, and though there will be growing pains, they will be addressed. However, once the dust has settled, I believe that the benefits will outweigh the difficulties.

SLPA’s should have their own licensure with continuing education requirements. Qualifications for SLPA’s should include no less than a bachelor’s degree in communication disorders or graduation from an accredited SLPA program. Intensive master’s programs and supervised clinical experiences are the basic qualifications for SLPs and we should not be considering assistants without specific instruction in speech-related topics. Any less than those standards places far too much of a burden on the supervising SLP to instruct the SLPA in the many areas of speech pathology. In terms of scope of practice, SLPA’s should not have any part of the assessment process. The document also stated that SLPA’s could not tabulate or interpret results of feeding/swallowing assessments and I feel this should be for all assessments not just feeding/swallowing. There needs to be a more clear cut set of guidelines (i.e. licensure and governing board) to the responsibilities of the SLPA. The statement regarding that the SLP supervising an assistant shall be responsible for determining whether the abilities of the SLPA are sufficient to ensure competency to perform tasks should again not be on the burden of SLP. The adoption of SLPA’s in Virginia could be of great value only if executed and governed appropriately.

I feel that licensure is needed for SLPAs.  The bachelor's degree term is too broad...any field of study bachelors degree or only speech language bachelor degrees?  The supervising SLP will still be responsible for planning the therapy sessions, supervising and being "responsible" for the scope of practice" that the SLPAs deliver. Licensure is necessary to protect the integrity of the services we provide.

 SLPAs should be required to have minimal educational requirements of a bachelor’s degree specific to communicative sciences and disorders.SLPAs should also comply with the requirements from ASHA.I am concerned about the supervision  of SLPAs though- it needs to be very specific and easy to manage for working SLPs.

Having read the proposal, I believe the initial qualifications for SLPA's are not restrictive enough. An SLPA should hold a bachelor's degree from an ASHA approved training institution OR an ASHA certified SLPA associate degree program (though I'm not sure ASHA certifies such programs at this time). In addition, an SLPA seeking employment in VA, having worked in that capacity in another state---no matter how long ---must meet the training criteria established by ASHA and/or the Commonwealth of VA. Additionally, as written, I feel the proposed language places the burden of competency of an SLPA too much on the supervising SLP. We need the stricter educational guidelines to help ensure that the consumer is receiving the best possible service reasonably available and afford the supervising SLP confidence that the SLPA is indeed as competent as possible with implementing a therapeutic plan across a variety of disorders. I'm not convinced that two observations per month per SLPA is enough to ensure best-practice.  I would also suggest that the proposal include regulations for mandated  annual continuing education for the SLPA.  Finally, I would  like to see a notation that the use of 'assistant' and similar terms that may be assigned to an individual working in the capacity of an SLPA be governed by this regulatory board. I appreciate that the proposal includes restrictions on an SLPA's scope of practice, including assessments, consultations, meetings, dissemination of client information,  inclusions and dismissals of clients etc. I will only feel comfortable advocating for employment of SLPA's in my workplace if these training criteria are mandated. Thank you.

I fully support the comment written by Susan Rose CCC-SLP, Gloucester Co. Public School. I could not write it better myself, so I simply say, “I second that comment completely.”

I support the alternative qualification for an assistant who has had employment as an SLPA in a US jurisdiction within the last 5 years preceding the effective date of the regulations.  I work in a Commonwealth of Virginia facility that has utilized SLP assistants for about 8 years. Some have had bachelor's degrees and some have not. We have been able to use them effectively to help us meet our demand for services-not by using them as "junior SLP's," but in supportive ways that do not include clinical duties that are restricted to an SLP. We work closely with them, and they are keenly aware of their boundaries. If SLPA's were to be licensed in Virginia, then they would be expected to have increased education and they could be used in a very different way; however, these proposed regulations are written for unlicensed assistants, and it is important to realize that it would be difficult to attract people into these unlicensed jobs if the qualifications were restricted to a bachelor's degree in communication disorders.

I would like to comment on 18VAC30-20-240 item D #5 which restricts the SLPA from participating in formal conferences or meetings without the presence of the supervising speech-language pathologist. In my facility, we do allow SLPA's to attend meetings in the absence of a SLP but they only are allowed to contribute general information cleared by the SLP in advance and they never discuss clinical issues. I suggest that #5 be rephrased to say that they should not participate in formal conferences or meetings where clinical information is provided without the presence of the supervising speech-language pathologist.  This also supports item #6 which makes it clear that they are not to provide interpretive information to the client or others.